On June 15, 2009, The California Supreme Court, in a case entitled People v. Dykes, upheld a decision of the trial court with the jury convicting him of first degree murder, attempted murder, and robbery, sentencing him to death. Under Miranda, a suspect may not be interrogated unless he knowingly and intelligently waived the right to remain silent and to an attorney. After the waiver, interrogation may proceed unless the suspect clearly asks for an attorney. The prosecution must prove the defendant's waiver by a preponderance of the evidence. In the instant case, the trial court applied the stricter "beyond a reasonable doubt" standard. The court gave credit to the officers' testimony that they had advised Dykes of his rights and that he did not ask for counsel.